The Federal Acquisition Regulation (FAR) is undergoing a historic rewrite. For decades, contractors have worked under a patchwork of rules layered with guidance, supplements, and agency interpretations. The current overhaul is intended to simplify, streamline, and modernize acquisition policy so it is easier for both agencies and industry to navigate.
To help agencies adopt the new structure, the FAR Council has issued model deviation texts for several key parts. These model deviations act as a bridge between the old system and the new streamlined framework. For government contractors, the release is more than just regulatory housekeeping. It signals how buying practices are changing and where opportunities may open.
This guide breaks down the new model deviations for FAR Parts 7, 24, 28, 30, 44, 46, 48, and 49. For each part, we will review the purpose, explain what has changed, and most importantly, show what it means for contractors in practical terms.
Key Differences at a Glance
Part 7 (Acquisition Planning): More emphasis on sustainability, supply chain resilience, and small business participation during planning. Contractors must make these connections visible in proposals.
Part 24 (Privacy & FOIA): Modernized rules for safeguarding personal data in digital systems and across subcontractors. Stronger clarity on protecting proprietary information from FOIA disclosure.
Part 28 (Bonds & Insurance): Updated thresholds for performance and payment bonds. Clearer insurance expectations for risk management.
Part 30 (Cost Accounting Standards): Simplified CAS applicability and exemptions. Easier compliance checks but greater accountability for midsize firms.
Part 44 (Subcontracting): Streamlined purchasing system reviews and stronger oversight of subcontracting practices. Primes face more accountability; small businesses gain new subcontracting opportunities.
Part 46 (Quality Assurance): Shifts responsibility for quality management onto contractors with less on-site government oversight. Documentation and strong QA programs are now critical differentiators.
Part 48 (Value Engineering): Simplified process for contractors to propose cost savings or performance improvements. Stronger incentives for agencies to adopt proposals.
Part 49 (Termination): Streamlined settlement procedures for terminations. Clearer expectations for both default and convenience terminations, especially subcontract handling.
Part 7: Acquisition Planning
What This Part Covers
Part 7 governs how agencies plan acquisitions. It requires contracting officers to identify needs, evaluate market conditions, and create acquisition strategies before issuing solicitations. Planning is where decisions about competition, set-asides, contract type, and source selection methods are made.
What Changed
The new model text simplifies requirements and integrates policy directives like sustainability, supply chain resilience, and small business participation directly into acquisition planning. Redundant language was trimmed, and references to modern planning tools were added.
What It Means for Contractors
For contractors, the planning phase is often invisible, but it determines whether you even get a shot at competing. Agencies now must tie procurement strategies more explicitly to government-wide policy goals. This creates several implications:
Proposal Preparation: Contractors should make it clear how their products or services align with broader federal priorities, such as cybersecurity resilience or green procurement.
Market Visibility: If your company is not visible in SAM.gov, DSBS, or market research platforms like FedBiz365, you risk being excluded early. Agencies will be documenting which vendors were considered at the planning stage.
Small Business Advantage: With stronger mandates to include diverse vendors, small and mid-tier businesses may find more opportunities if they are prepared to scale and prove past performance.
Part 24: Protection of Privacy and Freedom of Information
What This Part Covers
Part 24 governs how agencies protect personal information, sensitive data, and comply with the Freedom of Information Act (FOIA). It is critical in acquisitions involving IT systems, health data, or personally identifiable information.
What Changed
The revised text modernizes privacy requirements, particularly for digital environments and cloud services. It clarifies when data protections must flow down to subcontractors and strengthens requirements for safeguarding records that contain sensitive information.
What It Means for Contractors
IT and Data Contracts: If you handle government data, your compliance responsibilities have expanded. You will need to show how you protect personal and sensitive information, not just within your systems but also across subcontractors.
FOIA Risks: Contractors should remember that information submitted to the government may be subject to FOIA. The revisions clarify procedures for marking proprietary information, making it more important to properly safeguard trade secrets in your proposals.
Cybersecurity Alignment: Expect contracting officers to align privacy requirements with CMMC, NIST, and other frameworks. Contractors should proactively review policies to ensure internal practices align with government expectations.
Part 28: Bonds and Insurance
What This Part Covers
Part 28 sets requirements for bonds and insurance, particularly in construction and service contracts. It is designed to protect the government and ensure contractor performance.
What Changed
The model deviations update threshold amounts for when performance and payment bonds are required. They also align insurance requirements with modern risk management practices. Outdated references were eliminated, and language was clarified to reduce confusion.
What It Means for Contractors
Construction Firms: The changes affect when you must provide performance and payment bonds. Small contractors may face fewer upfront barriers if thresholds rise, making it easier to compete on mid-sized projects.
Risk Management: Agencies may be more explicit in requiring certain types of insurance coverage. Contractors should review their policies to ensure compliance and avoid award delays.
Cash Flow Considerations: Bonding remains a challenge for small businesses. Firms should maintain relationships with surety providers and be prepared to demonstrate financial health.
Part 30: Cost Accounting Standards (CAS)
What This Part Covers
Part 30 enforces the application of Cost Accounting Standards, ensuring consistency and fairness in how contractors allocate costs to government contracts.
What Changed
The updated text simplifies CAS applicability thresholds and clarifies exemptions. It also aligns with recent statutory updates to reduce burden on nontraditional contractors and small businesses.
What It Means for Contractors
Small Businesses: Many will remain exempt, but midsize firms approaching CAS thresholds should pay attention. Simplified guidance makes it easier to determine applicability, but failure to comply can be costly.
Transparency: Contractors subject to CAS must maintain strong internal controls. Agencies will be looking for consistent treatment of costs across contracts.
Competitive Edge: Firms that can show clean, CAS-compliant systems may gain an advantage in cost-reimbursement competitions.
Part 44: Subcontracting Policies and Procedures
What This Part Covers
Part 44 governs when contractors need government consent to subcontract and how purchasing systems are reviewed. It also establishes flowdown clauses for commercial subcontracts.
What Changed
The updated text makes the rules clearer and streamlines the Contractor Purchasing System Review (CPSR) process. It strengthens the government’s ability to monitor subcontracting practices, especially when costs are high or risks are significant.
What It Means for Contractors
Prime Contractors: You must maintain efficient, transparent purchasing systems. Without approval, you face more consent requirements, which can slow down performance.
Small Businesses: This is an opportunity. Primes are under pressure to meet subcontracting goals and prove system integrity. If your company is visible and compliant, primes may seek you out as a teaming partner.
FedBiz365 Advantage: For contractors looking to find primes, tools like FedBiz365 can highlight teaming opportunities, helping you get in front of large firms during the planning and proposal stages.
Part 46 establishes policies for ensuring products and services meet contract requirements. It covers inspections, warranties, and acceptance criteria.
What Changed
The model deviation text places greater emphasis on contractor responsibility for quality systems. Government reliance on contractor quality assurance has increased, with fewer on-site inspections in many cases.
What It Means for Contractors
Competitive Differentiator: Contractors with robust QA programs, certifications, and documented processes will have an edge.
Documentation: Agencies may rely heavily on your internal records. Poor documentation can create disputes or rejections.
Subcontract Oversight: You are responsible for ensuring subcontractor quality. Neglecting oversight could expose you to penalties or contract issues.
Part 48: Value Engineering
What This Part Covers
Part 48 encourages contractors to propose ways to reduce costs or improve performance after award. Accepted value engineering change proposals can result in shared savings.
What Changed
The revisions simplify procedures and clarify when value engineering is encouraged. Redundant language was removed, and references to commercial practices were added.
What It Means for Contractors
Opportunity for Savings: Contractors who propose cost-saving or performance-improving changes can share in the savings.
Stronger Incentives: Agencies are encouraged to adopt contractor suggestions more quickly, creating room for innovation.
Strategic Use: Contractors can use value engineering not just to save money but to strengthen relationships with contracting officers.
Part 49: Termination of Contracts
What This Part Covers
Part 49 covers procedures for terminating contracts for convenience or default. It sets rules for settlement, cost allowability, and subcontract handling.
What Changed
The revised text streamlines termination procedures, trims outdated guidance, and improves alignment with commercial practices. It provides clearer direction for small businesses on settlement claims.
What It Means for Contractors
Default Risks: Contractors must be proactive in documenting performance. Clearer rules mean less room for negotiation if you fall short.
Convenience Terminations: Settlement procedures are more straightforward, which should help contractors recover costs more efficiently.
Subcontract Flowdown: Contractors are responsible for ensuring subcontractors follow termination requirements. Poor oversight can complicate settlements.
Final Takeaways
The FAR overhaul is about clarity, speed, and accountability. The model deviations for Parts 7, 24, 28, 30, 44, 46, 48, and 49 reflect that goal.
For contractors, this is not just a legal update. It is a roadmap for how the government expects you to operate: more transparent, more accountable, and more proactive.
If you need help positioning your business under the new FAR framework, FedBiz Access has supported contractors for more than 24 years. From registrations and certifications to capability statements and direct marketing programs, we help businesses move from registration to award.
THE TEAM--Wayne-Frank-Ashley =A+ Team. All of them are there for you, and unlike many other places we interviewed, they are keen to answer your calls and questions in an expeditious manner. We never have to wait very long to get help. We tried many firms, and NONE can hold a candle to "THIS" team. Thx guys for your "CARING"
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I met Sidney Waters one year ago on a conference call. Really personable and ready to help companies become properly equipped government contractors.
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Although I haven't subscribed to Fed Biz Access, Sidney Waters has consistently checked in on our progress, providing "gold nuggets" and directing us to government resources. To be honest, he doesn't have to, but he's a quality individual. And for that, we appreciate him.
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1 month ago
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1 month ago
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1 month ago
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Al Hogan
1 month ago
I cannot say enough good things about Ashley Futral and the exceptional support she provided throughout my SBA and SDVOSB certification process.
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What impressed me most was her genuine dedication to her clients. She was always available to answer questions, provide updates, and offer expert advice throughout the process. Her communication was timely, clear, and professional, giving me confidence every step of the way.
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I also want to add I wouked with Mya Plant.
Mya Plant exceeded every expectation and delivered a capability statement that truly elevated our organization's professional image and marketability.
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If you are considering hiring Mya for capability statements, government contracting support, branding materials, or professional business documents, I recommend her without hesitation. Her expertise, customer service, and dedication to excellence are second to none.
Thank you, Mya, for your outstanding work and commitment to our success. We look forward to working with you again in the future.
— Professor Al Hogan
Owner, Team Randori Martial Arts
Retired U.S. Army CW4 | Veteran-Owned Business Owner
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Rita Hibbard
1 month ago
Very good company.
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2 months ago
Elizabeth Whitaker was exceptional, very helpful and was always there whenever we need her, thank you Elizabeth for being the great person that you are. We at Collins Henry, LLC is very grateful to have her working on our behalf....
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2 months ago
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2 months ago
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Stacy Hall
2 months ago
Trying to update anything with a govenrment agency is always a nightmare. After fighting with Sam.gov for weeks and getting nowhere, we reached out to Constance for help. She has made this SO much easier on us and gotten our account active again.
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2 months ago
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Minerva Finishes
2 months ago
Elizabeth Whitaker has been so very helpful to us. We are a very small business attempting to navigate the Government Contracts process. Elizabeth is quite knowledgeable, easy to understand and patient.
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Lynn Tyler
3 months ago
Elizabeth Whitaker helped me get my recertification. She made the process painless. She also helped me update my SAM.
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Schimpf's Garage
3 months ago
Cecilia and Sid go well above and beyond to assist me with registering my business with the VA and updating my profile with relevant business changes. Additionally, Frank is a master of contracting and has assisted us in navigating FedBiz's contracting databases and in reviewing proposed bids and contracts. I highly recommend this team to anyone seeking to register their business with the VA and applying for government contracts!
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3 months ago
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Ray Gould
3 months ago
Elizabeth Whittaker
handled our request for SDVOSB very efficiently
and we are most grateful for her assistance.
sincerely, ray gould Marine & Valve Supply
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Kati Gibbs
3 months ago
Love working with FedBiz! They are so communicative and helpful. Constance is such a pleasure to work with in getting our SBA profile set up, Lou is amazing at setting us up in FedBiz, and Frank is very informative when training us on FedBiz365. I highly recommend FedBiz!
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3 months ago
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John Diaz
3 months ago
Mya works very accurately and delivers high-quality work in creating our Capability Statement for the GSA organization. Highly recommend her and her organization, FEDBIZACCESS.
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Sandra Chen
3 months ago
Ashley Futral is exceptionally helpful, knowledgeable, and a pleasure to collaborate with. Her efficiency and swift communication have been invaluable, and I greatly appreciate her guidance throughout the process.
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Jacqueline Winter
4 months ago
FedBiz makes renewals so easy and simple which is great as when doing it directly with the gov't is so much more complicated! It was great working with Ashley Futral on on our latest renewal - she saved me so much time! She also helped sort out issues that came up with SAM that I don't think we could have solved on our own. Thank you!
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4 months ago
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4 months ago
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https://i0.wp.com/fedbizaccess.com/wp-content/uploads/2025/09/far-deviations.jpg?fit=1344%2C896&quality=89&ssl=18961344fedbizadminhttps://fedbizaccess.com/wp-content/uploads/2023/04/fedbizaccess-website-logo.pngfedbizadmin2025-09-30 17:02:562025-09-30 17:04:21FAR Overhaul Guide: What the New Model Deviations Mean for Contractors | Parts 7, 24, 28, 30, 44, 46, 48, and 49